# EPA Registration Jacket 4‐480T _ - --;;_. -'6-=-'

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# MATERIAL TO BE ADDElJ TO JACKET
REG# Description:

checkal!**th~~t**



# !;;:;a new stamped accepted label**~-**

# ~ 

# newCSF 

# o notification

Instructions: Attach this sheet to the top ofALL material sent to the file room (both loose paper and new material in jackets), This sheet will be imaged; a clear description will aid in finding material in the e-jacket. Remove staples from all material, If returning loose paper then hold together with a binder or paper clip. CSFs should be placed in the CSF folder (if returning jacket) or covered with a red CBI sheet (if returning loose paper).' Material to be returned to file room should bE) plaCE) inthe appropriate bin.
Reviewer's 

## hi Name: ''f2)I 

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Phone: 

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Division:

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## u.s. ENVIRONMENTAL PROTECTION AGENCY EPA Reg. Number: Date ofIssuance:**.$',~UJ ST"~**  

## f

...**'l'~** Office ofPesticide Programs 

### 4-480**,~.** Registration Division (7505P) 

# \.**~;** Ariel Rios Building 

## DEC -') c 

### 2CGj 1200 Pennsylvania Ave., NW ' 0 J:j, PRO'It: Washington, D.C. 20460 NOTICE OF PESTICIDE: Tcnn ofIssuance: 

### conditional 

## .x... Registration

_ Reregistration Name ofPes tidde Product: (under FIFRA., as amended) 

### Bonide MlMax Lawn Granules Name and Address ofRegistrant (include ZIP Code): Bonide Products, Inc. 630I SutliffRoad Oriskany, NY 13424 <Nilte::Cb'iiiiMiiS**;iiiJabelirig<di:ffe:rill·:ili~ribsilliic:e'frOmditiaraCci:** 'ted_ui'cODncdion";w5th lliis reO**lsniti~ii** mustbc**~$u!:ll11itted.to**and ace ted by t1ie

### ':-;ji'igjSf:ci[ronfbiViS'id~"1irioi-toUSb,ti.ilie':laber:jn,cominerce:'**:hi'~Y'6oiies'j;bnd'e;;2e'o;i-'ihis'IiJd1ict:3I~Ys**'rfie'?'fi,;fue' abOve'EPA ii:frai'ion'number. '
On the basis ofinformation furnished by thc registranI, the above named pesticide is hereby registered/reregistered UJIder the Federallnsecticide, Fungicide and Rodenticide Act. Registration is in no way to be construed as an endorscment orrecommendaIion ofthis product by the Agency. In order to protect health and the environment, the Administrator, on his motion, may at any time suspend or cancel the registration ofa pesticide in acco.tdance with the Act. The acceptance ofany name in connection with the registration ofa product under this Act is not to be construcd as giving the registrant a right to exclusive use ofthe name or to its use ifil has been covered by others. 

### This product is conditionally registered in accordance with FIFRA sec. 3(c)(7)(A) provided that you:
1. 

### Submit and/or cite all data required for registration/reregistration review ofyour product whenthe Agency requires all registrants ofsimilar products to submit data; and submit acceptable responses required for reregistration ofyour products under FIFRA section 4. 

# 2. Make the following label cbanges: a. Revise the "Precautionary Statements" to read: "Harmful ifswallowed, inhaled or absorbed through skin. Causes moderate eye irritation. Avoid contact with skin, eyes or clothing. Avoid breathing dust. Wash thoroughly with soap and water after handling. Remove and wash contaminated clothing before reuse." 

# 3. Revised the orderofthe "First Aid" statements are so they are listed as follows: "Ifin eyes", "Ifswallowed", "Ifon skin", and "Ifinhaled".

0 Signature ofApproving Official: I Date: 

# r0J1**~** 

# '1**~** Kathryn V. Montagu. i**'-~,** : 

# IIJt

...**~**

# ~~r~~~:d~:~~~23\ .;

# [~\;~I\' c', c- f"' C C IF-' "--'-'

'0 

### Registration Division (7505P) EPA Fonn 8570-6

### page 2 EPA Reg. No. 4-480

year from the date ofthis Notice, conduct one year studies for guidelines 830.6317 (storage stability) and 830.6320 (corrosion characteristics). Samples 

### must be analyzed at 3, 6, 9 and and 12 months. They should be submitted in electronic and hard copy format.
Submit one copy ofthe revised printed labels for the record. Ifthese conditions are not complied with, the registration will be subject to cancellation in accordance with FIFRA sec. 6(e). Your release for shipment ofthe product constitutes acceptance ofthese conditions.
A stamped copy ofthe label is enclosed for your records.i 

# Bonide MMax Lawn Granules

[*Kills lawn Moss Quickly 

### J [*See Results in Hours 

### J [*Covers lip to 5/000 sq.ft. 

## 1 [*Kills patches of unwanted moss 

### J [*ReadY-To-Use granules 

### J [*Easy to use J [ *With 7% Iron J [*Turns lawns a deep green 

### J [*No excess growth, less mowing}
Active Ingredient: 

# 20-0-5

Ferrous Sulfate Monohydrate

.............. 23.5% Inert Ingredients:

.................................. 76.5% Keep out of reach of children CAUTION 

### ACCEPTED witb COMMENTS 

### In EPA

### LetterDated: 

## DEC 2 9 2C09**u~ ~**Federal In: ;ticidc, FUIlglcide, and Rcxlerll1cideAct as**~ded.** for the pesticide reg""",," underEPA"""No

## 1~ 

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See back panel for additional precautionary statements and First Aid
NET WT.
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, , , >PRECAUTIONARY STATEMENTS HAZARDS TO HUMANS AND DOMESTIC ANIMALS CAUTION: Causes eye irritation. Do not get in eyes, on skin or clothing. Harmful ifswallowed, inhaled or absorbed through skin. Avoid breathing dust. Remove contaminated clothing and 

### wash before reuse. Wash thoroughly with soap and water after handling and before eating or smoking. Do not allow persons or pets in treated areas until granules have been watered in and 

### treated area is dry.
FIRST AID IF SWAllOWED: Call a poison control center or doctor immediately for treatment advice. Have 

### person sip a glass of water if 

### able to swallow. Do not induce vomiting unless told to do so 

### by a poison control center or doctor. Do not give anything 

### by mouth to an unconscious person. IF IN EYES: Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing. Call 

### a poison control center or doctor for treatment advice. IF ON SKIN OR CLOTHING: Take off contaminated clothing. Rinse skin immediately with plenty of water for 15-20 minutes. Call a poison control center or doctor for treatment advice. iF INHALED: Remove person to fresh air. If person is not breathing, call 911 or an ambulance, then give artificial respiration, preferably mouth-to-mouth if possible. Call a poison control center or doctor for further treatment advice. Have the product container or label with you when calling a poison control center or doctor or going for treatment.
ENVIRONMENTAL HAZARDS Do not apply directly to water. Do not contaminate water when disposing of equipment washwaters. To protect the environment, do not allow granules to enter or run off into storm drains, drainage ditches, gutters or surface waters. Applying this product in calm weatherwhen rain is not predicted for the next 24 hours will help to ensure that wind or rain does not blow or wash pesticide offthe treatment area. Sweeping any product that lands on a driveway, sidewalk, or street, back onto the treated area ofthe lawn or garden will help to prevent run off to water bodies or drainage systems.

DIRECTIONS FOR USE It is a violation of Federal law to use this product in a manner inconSistent with its labeling. For residential use only. Not for use indoors. 

### " , , 

### , IRON Will STAIN. Use this product on lawns and around flowers and**orname~tar)s~rubs.** 'Reep this product offsurfaces such as sidewalks, patios, wooden decks, driveways a'nd 'clc'Hhin&. >, , , , " , }} , , , > Sweep concrete surfaces immediately to prevent staining. If concrete is wet**wh~n** (;ontact occurs, staining may be impossible to prevent. :,' ,;

., , " RATE OF APPLICATION ", , '" , ", ,For normal infestations of moss, apply this product at the rate of 4 pounds per 1,000 sq.ft. A 20 lb. bag will cover 5,000 sq.ft. For heavy infestations ofmoss, apply at the rate of 8 pounds per 

### 1,000sq.ft. A20 lb. bag will cover 2,500 sq.ft.
Lawn moss thrives in damp, shady areas where the soil is acidic and drainage may be poor. If steps are not taken, moss can spread and take over a lawn. MMax Lawn Granules wi!! quickly kill lawn moss, giving your lawn grass the opportunity to fill in and reclaim the lawn.
For best results, apply this product when the lawn is moist. Mow before application, to better expose existing moss and water in to activate the product. [Claimforformula containing no N-P-Kfertilizer:} You can now enjoy a beautiful moss free lawn with no excess growth & less mowing.
As ASpot Treatment In LAWNS and around Ornamental Shrubs and Flowers: Apply anytime moss is actively growing and soil is moist. Sprinkle granules over the mossy area. Immediately after application, water-in. Wait several days until the moss turns black and dies, then gently rake it out.
IMPORTANT: This product can burn delicate foHage if applied d'lrectly to flowers and ornamental shrubs. If contact does occur, use a garden hose to wash the product off ofthe plants immediately.
SPREADER SETIINGS (Insert standard spreader setting chart)
GUARANTEED ANALYSIS [example]: Total Nitrogen (N)

.... 20% Soluble Potash (K20)

.... 5% Iron (Fe)

.... 7%
Derived from ammonium sulfate, urea, muriate of potash, ferrous sulfate.
Information regarding the contents and levels of metals in this product is available on the internet at http://www.aapfco.org/metals.htm.

STORAGE AND DISPOSAL Pesticide Storage: Store and transport in an upright position. inaccessible to children. Store in a cool dry area " " " 

# . " , , , " 

### , Pesticide Disposal: Jf partly filled

- Call your local solid waste agency for

## dispo~al**(n~trucbon;.,** ,,'''' ".,"> Never place unused product down any indoor or outdoor drain. ;;' Container Disposal: Jfempty

- Nonrefillable container. Do not reuse or refill this

### 'c'ontain~, ' , ;

, " " Place in trash or offer for recycling if available. ", 

### , ,', 

### ,

, " 

### , ,

, , , ,To the extent consistent with applicable law, buyer assumes all risks of use, storage or handling ofthis product not in strict accordance with directions given herewith.
Bonide Products, Inc. 6301 Sutliff Road Oriskany, NY 13424

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### DATE OUT: 10/28/09
SUBJECT: FEE PRODUCT CHEMISTRY REVIEW OF MP [] EP [X] DP BARCODE No.: D368665 REG. No. 

### IFile Symbol No. 4-UIN PRODUCT NAME: BONIDE MMAX LAWN GRANULES PCC: 050507 Decision No. 418493 FOOD USE [] COMPANY: BONIDE PRODUCTS, INC.

FROM:

# ~ \0\"';;"0"1 Indira Gairola, Chemist Q-r 

### Product Chemistry Team 

### ('M _, h 

### I 

# D\V 

# I/I 

### I Technical Review BranchiRD (7505P) 

### b V 

# oVv , TO: Joanne Miller 

### I Dianne Morgan PM 23 Herbicide BranchiRD (7505P)

INTRODUCTION:

BONIDE PRODUCTS, INC is seeking registration for the subject product BONIDE MMAX LAWN GRANULES. Applicant claims the subject product BONIDE MMAX LAWN GRANULES to be a "Me Too" ofEPA Reg. #s 538-223, 802-543, 8660-178 and 9240-8. Applicant has submitted Basic CSF dated 

### 08/04/09. The submitted package was reviewed and details 

### will be discussed below:

SUMMARY OF FINDINGS:

I. 

### The subject product BONIDE MMAX LAWN GRANULES contains 23.5 % 

### ofFerrous Sulfate Monohydrate. 2. BONIDE PRODUCTS, INC has submitted MRlD # 478284-01 for Product Chemistry data to support the registration ofBONIDE MMAX LAWN GRANULES. 3. The source ofactive ingredient listed for the subject product is not registered. 4. The inert used is approved for non-food use.2



### 5. Basic CSF dated 

### 08/04/09 for the subject product meets the label claim of. 23.5 % 

### of Ferrous Sulfate Monohydrate.
6 Data corresponding Sub Group A completely satisfy the data requirements of 40CFR§ 158.320 to §158.355.
7. Product Chemistry Data for the Sub Group B for the proposed New Product have been 

### satisfied. 8. Applicant needs to submit Storage Stability and corrosion characteristics study Data for 3, 6, 9 and 12 months, these data are a requirement. 9. The subject product BONIDE MMAX LAWN GRANULES cannot be considered to be a "Me Too" ofEPA Reg. #s 538-223, 802-543, 8660-178 and 9240-8 since there is difference of concentration ofactive ingredient in all ofthe cited EPA Reg. #s when compared to the concentration of(23.5 % 

### Ferrous Sulfate Monohydrate) for the subject product.

CONCLUSIONS:

TRB has reviewed the product chemistry data submitted for the above mentioned subject product and has concluded that:

1. The subject product BONIDE MMAX LAWN GRANULES 23.5 % ofFerrous Sulfate Monohydrate.
2 The label claim is in compliance with PR Notice 91**~2.** 

### 3. Basic CSF dated 08/04/09 for the subject product meets the label claim of23.5 % 

### of Ferrous Sulfate Monohydrate is acceptable conditionally. 4. The product chemistry data requirements for series 830 Sub Group A and sub group B for the proposed New product are completely satisfied.Registration

### ofJ:h~__

### ~_!lQj~ctp:r:oduc.tis_ 

## -+- contingent to the registration ofthe technical used to fonnulate this product. 5. The registrant to submit sub group a & 

### sub group B data for the unregistered Ferrous sulfate monohydrate3

BARCODE No.: 

### D368665 LAWN GRANULES File Symbol No.: 4-UIN PRODUCT NAME: 

### BONlDE MMAX

Data Required Fulfilled MRID No. PRODUCT CHEMISTRY DATA (SERIES 830 Subgrou(;! A & SubgrouQ IDSubQroup A
830.1550. Chemical Identity (Basic CSF) Afw comments Basic 08/04/09 830.1600. Beainnina Materials A 478284-01 30.1650. Formulation Process A 478284-01 830.1670. Discussion of Impurities A 478284-01 830.1700. Preliminary Analysis NA 830.1750. Certified Limits (Basic CSF) A Iwith comments Basic 08/04/09 830.1800. Enforcement Analytical Method A 478284-014

PRODUCT CHEMISTRY Qata Reguired Value or Qualitat. DescriQ. MRID No. DATA Fulfilled (SERIES 830 Subgroup 8)

830.6302. Color A Black, j:Jrey, yellow and while Qranules 478284-01 830.6303. Ph sical Slate A Solid qranules 478284-01 830.6304. Odor A Typical synthetic Fertilizer odor 478284-01 830.6314. Oxidation/Reduction NA Does not contain any ingredientthat is Action oxidizing or reducing agent 830.6315. Flammability NA Does not contain combustible liquid 830.6316. Explodability NA Product does not contain combustible liquids 830.6317. Sioraqe stability I I 830.6319. Miscibilit NA Not intended for dilution with pel solvents 830.6320. Corrosion I I Characteristics 830.6321. Dialect Bkd. Vilg. NA 830.7000. pH A 6.1 @20'C (5% in water) 478284-01 830.7100. Viscosity NA 830.7300. Density/Bulk A 57lbs/cubic ft.lbulk density 478284-01 Density Explanations; Y The Requirements Were Fulfilled; N The Requirements Were Not Fulfilled; NA

- Not applicable;



# - - G - Data Gap, U ReqUIres Upgrading, I Incomplete or In Progress, W _ Waived.#4-UIN P.C. Code 050507



### UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY WASHINGTON, D.C. 20460
OFICE OF PREVENTION, PESTICIDE AND TOXIC SUBSTANCES 

### Similarity action



### MEMORANDUM November 9, 2009 _Subject: EPA Reg. No.: 4·UIN 

### 368666 418493 R30l 050507 Bonide MMAX Lavvn Granules

From:



### To: DB Code; Decision; Mail Code: 

### P.e. Code:
Masih Hashim, Toxicologist Technical Review Branch Registration Division (7505P) Dianne Morgan, RM Team 23 Herbicide Branch Registration Division (7505P)
Applicant: Bonide Products, Inc.

FORMULAnON FROM LABEL: Active Ingredient(s); Ferrous sulfate monohydrate Inert Ingredient(s): 

### Total: % 

### bywt. 24.7 

### 75.3 100.0%

ACTION REQUIRED: To detennine ifthe cited and the proposed products are substantially similar.RECOMMENDATIONS:
The cited and the proposed products are substantially similar in toxicity. The active in the cited is lower (at 17.5%) than the proposed product, however, the data can be bridged between the cited 

### product and technical Ferrous sulfate monohydrate for all exposure routes except eye. For eye exposure, theRegistranthas cited eye irritation study 

### (MRlD 44770403) conductedona formulation containing 24.5% Ferrous sulfate monohydrate.
The CSF for the proposed product should be approved by Chemistry, as a requirement. The proposed product 

### will have the same label as the cited product
The acute toxicity profile for the File Symbol is as follows:

acute oral toxicity acute dermal toxicity acute inhalation toxicity primary eye irritation primary skin irritation dennal sensitization

LABELING: 

### III III III III IV**non~sensitizer**



### 1. The signal word is "CAUTION". bridged #538-223 and technical bridged #538-223 and technical bridged #538-223 and technical cited- MRID 44770403 bridged #538-223 and technical bridged #538-223 and technical 

# ,'V 1 !'\.{jj'f-' , -I 

# -vNYVy",,'iY 

# 10J",**~\** 

# ;:; 'i}'

# ~!f:.!!**~\j~ \';~#'** **~,V" v'D-)_~,** **_:c~,"** 

# i0 2. The precautionary statements should state:**~** 

# '<

_**~** "Ranufulifswallowed, inhaledor absorbedthrOU4skin. Causesmoderate eye irritation. Avoid contactwithskin, eyes or clothing. Avoid

### breathint dust. Washthoroughly with soap and water after handling. Remove and wash contaminated 

### crthing before reuse."
3. The statements ofpractical treatment should state) 

### "If 

### in eyes: Flush 

### with plenty ofwater. Call a physician ifirritation persists." 

## Hlfswallowed: Call a physician or Poison Control Center. Drink 1 or 2 glasses ofwater and induce vomiting by touching back ofthroat with finger. Do not induce vomiting in or give anything by mouthto an unconscious person." 

### "If 

### on skin: Wash with plenty ofsoap and water. Get medical attention," 

### "If inhaled: Remove victim to fresh air. lfnotbreathing, give artificial respiration, preferably mouth-to-mouth, Get medical attention,!!

# •

B. Human Health Assessment

1. ToxicoJogy Assessment The toxicological data base on iron (Ill) sulfate"'. iron (D) sulfate monohydrate. and iron (II) sulfate heptahydrate is**~:late** and wi[. support reregistration eligibility.



### a. Acute and Subchronic Toxiclty

ACUTE TOXICITY VAWl'S

TEST "RESULT TOXICITY Iron 1II Sulfate CATEGORY Oral LD,.,--rat 1487

- 2102 mg/kg ill 

### Inhalation LC')"o--rat 

### > 1.10 mglL ill Dermal**LD.)"o~-rabbit** >2000 mg/kg 

### III Eye Irritation corrosive I Dennal Irritation corrosive N Dermal Sensitization negative 

# - Iron (III) sulfate. in an acute .oral study in rats, had an LDso of 1487 mg/kg in females and 2102 mg/kg in males. An acute dermal toxicity test in rabbits with Iron (III) sulfate found an LDso 

### greater than 2000 mglkg. An acute inhalation toxicity study in rats using iron (ill) sulfate determined the LCso to 

### be greater than 1.10 mglL. Iron (II) sulfate heptahydrate, in an acute oral study in rats. showed an LD

.. of 1389 mg/kg and an acute oral study 

### in rabbits showed an LD

.. of 2778 mglkg(4). The LD", determined for this compound in mice was 1520 mg/kg(4). A sensitization study using guinea pigs with iron (II) sulfate monOhydrate and iron (llI) sulfate found no indication of contact sensitization by this compound.



### 7

# •

2. h. Mutagenicity A mutation study in 

## E:. £Q)i reported poJitke r:sult'i at 3'1 umoIlL(4). With due regard for the continuing**~xposll,e** Cla: huna"} beings have had to the iron and sulfate components ofthese chemicals 

### over many generations. it 

### is considered unlikely that this 

### reported 

### result in microorganisms has any bearing on probable**~~fl!Ct** ... in hHtm.nS or other mammals at the levels expected from use ofthe!:e COM}>O·mds as pesticides.

c. Metabolism Iron sulfates are normal constituents of the diet and are metabolized and utilized by the body. 

### d. Other Toxicological Consideration The toxicological data on iron sulfates within the A d in the literature are adequate for assessi" risk to humans. Not all of the tox.icity data usually requIred for pesticide registration or reregistration are necessary for the present uses of iron sulfates. There are some unusual factors in this case which indicate that specific studies 

### to fulfill the usual data requirements are not necessary to regulate these substances as pesticides. Iron sulfates are normally present in the environment. They may be present in foods naturally and 

### as added ingredients. There is no reason to expect that pesticide usage in accordance with the product label or labeling accompanying the product will constitute any hazard beyond that from ordinary exposure. 

### Exposure Assessment



### a. Dietary Dietary exposure to iron (HI) sulfate, iron (II) sulfate neptahydrate, and iron (II) sulfate monohydrate is not expected to occur from pesticidal use. There are no active products involving 

### pesticidal uses on food or animal feed. Therefore, there are no tolerances or exemptions from the requirements of tolerances established for iron salts. Since there are 

### no toxicological endpoints of concern and no food uses, no risk assessment was perfonned for dietary exposure. Iron (II) sulfate is generally recognized as safe as noted in 40 CFR 180.2(a). The Food and Drug Administration has affinned that iron (Jll) sulfate and iron (II) sulfate (hopta and monohydrate) are generally recognized as safe (GRAS) for use in 

### food as flavoring agents and nutrient supplements. respectively. with no limitations other than


### 8

### April 5, 1999 MEMORANDUM EPA File Symbol: 8660-RAI STA-GREEN MOSS CONTROL GRANULES DP Barcode: D254800 Case No: S558453 PC Code: 050507 Ferrous**su~ate** 

### monohydrate From: Byron T. Backus, PhD., Toxicologist Is/Byron T. Backus Technical Review Branch 4/5/99 Registration Division (7505C) To: Dianne Morgan/Joanne Miller, PM 23 Herbicide Branch Registration Division (7505C) Registrant: PURSELL INDUSTRIES, INC. ACTION REQUESTED: "The registrant has submitted an application for registration oftheir product. They forwarded four acute toxicity studies for review. I have also attached the proposed CSF and labeling. Please review for acceptability." BACKGROUND: The package, as received by this reviewer, contains the following four acute toxicity studies: acute oral LD50 (rat) in MRID 44770401; demnal LD50 (rat) in MRID 44770402; primary eye irritation (rabbit) in MRID 44770403); and dermal irritation (rabbit) in MRID 44770404; however, it does not include a copy of any labeling, and the CSF is for EPA Reg. No. 8660-178. According to informati n the regl ofs cover letter the purpose of this submission "is to support the continu registration of Pursel Industries, Inc. ferrous 

### sulfate monohydrate EPA pesticide product

.. 660-178; 8660-248 nd 8660-RAI.

.." and "all four tox studies to be placed in the file for golde igoro moss co 01 

### plus lawn fertilizer EPA Reg. No. 8660-178 (A.I. 24.5% ferrous

sulfate monohydrate)." COMMENTS AND RECOMMENDATIONS: 1. The CSF attached to this action is that for EPA Reg. No. 8660-178, which, according to REFS, has 24.5% ferrous sulfate monohydrate as its sole active ingredient. This is consistent with the information in the CSF. However, the bean sheet indicates


### 1

### )



### . that this action is for Et,-( 

### File Symbol 8660-RAI, and the**b~** ,J 

### sheet also indicates that this product contains 32.0% ferrous sulfate monohydrate as (presumably) sole active ingredient. According to information in each individual report (oral study on page 8, dermal study on page 7, eye irritation on page 8, dermal irritation study on page 7) the active ingredient in the tested formulation was ferrous sulfate monohydrate at 24.5%. 2. Each of the four studies has been reviewed and classified as acceptable. A partial acute toxicity profile ofthe tested formulation is given below: Acute Oral LD50 Acute Dermal LD50 Acute Inhalation LC50 Primary Eye Irritation Primary Dermal Irritation Dermal Sensitization 

### III 

### IV

III 

### IV Acceptable Acceptable Not included Acceptable Acceptable Not included 3. Although each ofthese four studies has been classified as acceptable, they can only be used to support the registration of products containing 24.5% (or less) ferrous sulfate monohydrate as sole active ingredient. If, as indicated on the bean sheet, the 

### proposed product 8660-RAI contains 32% ferrous sulfate monohydrate, then these studies cannot be used (or cited) in support ofthat registration.



### 2DATA REVIEW FOR ACUTE ORAL TOXICITY TESTING (870.1100, formerly §81·1) Product Manager: 23 MRID No.: 44770401 Reviewer: Byron 

### T. Backus, PhD. Study Completion Date: January 15, 1999 Study No.: 6764 Testing Facility: Product Safety Labs Author: Moore, G.E. Quality Assurance (40 CFR §160.12): Included (p. 20) Test Material: Moss Control 

### + Lawn Fertilizer, Code #522228; beigeltan and gray granules, with ferrous sulfate monohydrate 24.5% and inert ingredients (fertilizer) 75.5%. Species: Rat; Albino,**Sprague~Dawley** derived Age: "Young adult" Weight: Males: 215-248 g; Females: 166-204 9 Source: Ace Animals, Inc., Boyertown, PA Conclusion: 1. LDso (mg/kg): Males: between 500 and 5000 mg/kg Females: between 500 and 5000 mg/kg Combined: between 500 and 5000 mg/kg 2. The estimated LDso is > 500 mg/kg 3. Tox. Category: III Classification: Acceptable Procedure (including deviations from 870.1100): "Prior to administration, the test substance was ground to a fine powder using a coffee mill... The ground sample was then administered as a 50% w/w suspension in distilled water. Preliminary solubility testing

...indicated that suspensions in excess of 50% 9i.e., 60-80%) were too viscous to be administered properly." "Due to a technician error, bodyweights and necropsies for the 500 mg/kg dose level were performed on Day 13 instead of Day 14." Results' 

# . Number of Deaths/Number Tested Dosage (mg/kg) Males Females Combined 500 

### 0/5 0/5 0/10 5000 

### 515 515 10/10
Observations: At 500 mg/kg all rats survived and gained weight, with no indication of toxicity. At 5000 mg/kg all rats died within 21 hours of administration. ''Toxic signs prior to death

... included hypoactivity and hunched or prone posture." Gross Necropsy: At 500 mg/kg no gross abnormalities were noted at necropsy. At 5000 mg/kg "gross necropsy of the decedents revealed discoloration of the lungs, stomach and gastrointestinal tract."



### 3

### April 5, 1999 MEMORANDUM EPA File Symbol: 8660-RAI STA-GREEN MOSS CONTROL GRANULES DP Barcode: D254800 Case No: S558453 PC Code: 050507 Ferrous sulfate monohydrate From: Byron T. Backus, PhD., Toxicologist Is/Byron T. Backus Technical Review Branch 4/5/99 Registration Division (7505C) To: Dianne Morgan/Joanne Miller, PM 23 Herbicide Branch Registration Division (7505C) Registrant: PURSELL INDUSTRIES, INC. ACTION REQUESTED: "The registrant has submitted an application for registration oftheir product. They forwarded four acute toxicity studies for review. I have also attached the proposed CSF and labeling. Please review for acceptability." BACKGROUND: The package, as received by this reviewer, contains the following four acute toxicity studies: acute oral LD50 (rat) in MRID 44770401; dermal LD50 (rat) in MRID 44770402; primary eye irritation (rabbit) in MRID 44770403); and dermal irritation (rabbtt) in MRID 44770404; however, it does not include a copy of any labeling, and the CSF is for EPA Reg. No. 8660-178. According to infonnation in the registrant's cover letter the purpose of this submission "is to support the continued registration of Pursell Industries, Inc. ferrous sulfate monohydrate EPA pesticide products

...8660-178; 8660-248 and 8660-RAI.

.. " and "all four tox studies to be placed in the file for golden vigoro moss control plus lawn fertilizer EPA Reg. No. 8660-178 (A.I. 24.5% ferrous

sulfate monohydrate)." COMMENTS AND RECOMMENDATIONS: 1. The CSF attached to this act'lon is that for EPA Reg. No. 8660-178, which, according to REFS, has 24.5% ferrous sulfate monohydrate as its sale active ingredient. This is consistent 

### with the information in the CSF. However, the bean sheet indicates


### 1

### that this action is for E,

. )File Symbol 8660-RAI, and the bE Isheet also indicates

.that this product contains 32.0% ferrous sulfate monohydrate as (presumably) sole

active ingredient. According to information in each individual report (oral study on page 8, dermal study on page 7, eye irritation on page 8, dermal irritation study on page 7) the active ingredient in the tested formulation was ferrous sulfate monohydrate at 24.5%. 2. Each of the four studies has been reviewed and classified as acceptable. A partial acute toxicity profile of the tested formulation is given below: Acute Oral LD50 Acute Dermal LD50 Acute Inhalation LC50 Primary Eye Irritation Primary Dermal Irritation 

### Dermal Sensitization 

### III IV



### III IV Acceptable Acceptable Not included Acceptable Acceptable Not included 3. Although each of these four studies has been classified as acceptable, they can only be used to support the registration of products containing 24.5% (or less) ferrous sulfate monohydrate as sole active ingredient. If, as indicated on the bean sheet, the proposed product 8660-RAI contains 32% ferrous sulfate monohydrate, then these studies cannot be used (or cited) in support of that registration.

2DATA REVIEW FOR ACUTE ORAL TOXICITY TESTING (870.1100, formerly §81-1) Product Manager: 23 MRID No.: 44770401 Reviewer: Byron 

### T. Backus, Ph.D. Study Completion Date: January 15, 1999 Study No.: 6764 Testing Facility: Product Safety Labs Author: Moore, G.E. Quality Assurance (40 CFR §160.12): Included (p. 20) Test Material: Moss Control 

### + Lawn Fertilizer, Code #522228; beigeltan and gray granules, with ferrous sulfate monohydrate 24.5% and inert ingredients (fertilizer) 75.5%. Species: Rat; Albino,**Sprague~Dawley** derived Age: "Young adult" Weight: Males: 215-248 g; Females: 166-204 9 Source: Ace Animals, Inc., Boyertown, PA Conclusion: 1. LD" (mg/kg): Males: between 500 and 5000 mg/kg Females: between 500 and 5000 mg/kg Combined: between 500 and 5000 mg/kg 2. The estimated LD50 is > 500 mg/kg 3. Tox. Category: III Classification: Acceptable Procedure (including deviations from 870.1100): "Prior to administration, the test substance was ground to a fine powder using a coffee mill... The ground sample was then administered as a 50% w/w suspension in distilled water. Preliminary solubitity testing

...indicated that suspensions in excess of 50% 9i.e., 60-80%) were too viscous to be administered properly." "Due to a technician error, bodyweights and necropsies for the 500 mg/kg dose level were performed on Day 13 instead of Day 14." Results-


# . Number of Deaths/Number Tested Dosage (mg/kg) Males Females Combined 500 

### 0/5 0/5 0110 5000 

### 515 515 10/10
Observations: At 500 mg/kg all rats survived and gained weight, with no indication of toxicity. At 5000 mg/kg all rats died within 21 hours of administration. "Toxic signs prior to death

... included hypoactivity and hunched or prone posture." Gross Necropsy: At 500 mg/kg no gross abnormalities were noted at necropsy. At 5000 mg/kg "gross necropsy of the decedents revealed discoloration ofthe lungs, stomach and gastrointestinal tract."



### 3DATA REVIEW FOR ACUTE DERMAL TOXICITY TESTING (870.1200. fonnerly §81·2) Product Manager: 23 MRID No.: 44770402 Reviewer: Byron 

### T. Backus, Ph.D. Study Completion Date: January 15, 1999 Study No.: 6765 Testing Facility: Product Safety Labs Author: Moore, G.E. Quality Assurance (40 CFR §160.12): Included (p. 15) Test Material: Moss Control + Lawn Fertilizer, Code #522228; beigeltan and gray granules, with ferrous sulfate monohydrate 24.5% and inert ingredients (fertilizer) 75.5%. Species: Rat; Albino, Sprague-Dawley derived Age: "Young adult" Weight: Males: 226-258 g; Females: 211-240 9 Source: Ace Animals, Inc., Boyertown, PA Dermal LD 5(} Testing: Conclusion: 1. LD" (mglkg): Males: > 2000 mg/kg Females: > 2000 mg/kg Combined: > 2000 mg/kg (no mortality during the study) 2. The estimated LD 5(} is > 2000 mglkg 3. Tox. Category: III Classification: Acceptable Procedure (including deviations from 870.1200): "Prior to application, the test substance was ground to a fine powder, using a coffee mill.

.. The ground test substance was then moistened to achieve a dry paste by preparing an 80% w/w mixture in distilled water. Two thousand mg/kg ofthe test material was placed on one 2"x3", 4-ply gauze pad, then applied to a dose area of approximately 2"x3" (approximately 10% of the body surface)." There was 24-hr occluded dermal exposure. Results" 

# . Number of Deaths/Number Tested Dosage (mglkg) Males Females Combined 2000 015 015 0110 Observations: No rats died during the study. All gained weight and appeared active and healthy, with no signs "of gross toxicity, adverse pharmacologic effects or abnormal behavior." Gross Necropsy: No gorss abnormalities were found.



### 4DATA REVIEW FOR PRIMARY EYE IRRITATION TESTING (870.2400, formerly §814) Product Manager 23 MRID No.: 44770403 Reviewer: Byron T. Backus, Ph.D. Study Completion Date: January 15,1999 Study No.: 6766 Testing Facility: Product Safety Labs Author: Moore, G.E. Quality Assurance (40 CFR §160.12): Included (p. 18) Test Material: Moss Control 

### + Lawn Fertilizer, Code #522228; beige/tan and gray granules, with ferrous sulfate'monohydrate 24.5% and inert ingredients (fertilizer) 75.5%. Dosage: 0.1 mL (0.07 to 0.08 g) Species: Rabbit; Albino, New Zealand White Age: "adult" Weight: not reported Source: Davidson's Mill Farm, South Brunswick, NJ Conclusion: 1. Toxicity Category: III (Moderate irritant) 2. Classification: Acceptable Procedure (including deviations from 870.2400): Only 3 rabbit eyes were tested. "The test substance was instilled after being ground to a fine powder, using a coffee milL

.." A fluorescein dye procedure was used at 24 hours.
Number "positive"/number tested Hours Days Observations 1 24 48 72 4 7 10 Unwashed eyes Corneal Opacity 

### 01 01 01 0/3 01 nd nd 3 3 3 3 Iritis 

### 01 01 01 0/3 01 nd nd 3 3 3 3 Conjunctivae: Rednessa 

### 31 31 31 0/3 01 nd nd 3 3 3 3 Chemosisa 

### 21 

### 31 21 0/3 01 nd nd 3 3 3 3 Dischargea 

### 21 31 11 0/3 01 nd nd 3 3 3 3 nd

- not done aScore of 2 or greater considered as a positive response Summary: "No corneal opacity or iritis was noted during the study. All animals exhibited conjunctival irritation between one and 72 hours. All animals were free of ocular irritation within 4 days

..."



### 5DATA REVIEW FOR PRIMARY DERMAL IRRITATION TESTING (870.2500, formerly §81·5) 

### Product Manager: 23 MRID No.: 44770404 Testing Facility: Product Safety Labs Author: Moore, G.E. Reviewer: Byron T. Backus, Ph.D. Study Completion Date: January 15, 1999 Study No.: 6767

Quality Assurance (40 CFR §160.12): Included (p. 16) Test Material: Moss Control 

### + Lawn Fertilizer, Code #522228; beige/tan and gray granules, with ferrous sulfate monohydrate 24.5% and inert ingredients (fertilizer) 75.5%. Dosage: 0.5 9 Species: Rabbit; Albino, New Zealand White Age: "Adult" Weight: not reported Source: Davidson's Mill Farm, South Brunswick, NJ Conclusion: 1. Toxicity Category: IV (Slight irritant) 2. Classification: Acceptable Procedure (including deviations from 870.2500): Only three rabbits were used. "Prior to application, the test substance was ground to a fine powder, using a coffee mill... The ground sample was then applied as an 80% w/w mixture in distilled water." "Five-tenths of a gram of the test substance (dry weight basis) was placed on a 1" x 1", 4-ply gauze pad, then applied to one 6 cm 2 intact dose site on each animaL

.." There was 4-hr occluded exposure. Results: One of the three animals had a score of "1" for erythema at 1 hourafter patch removal, all other subsequent scores for erythema (at 24, 48 and 72 hrs) were zero. All scores for edema were zero. The PII (average of 1, 24, 48 and 72 hr scores) was 0.075. Special Comments: None



### 6ACUTE TOX ONE-LINERS 1. DP BARCODE: D254800 2. PC CODE: 050507 Ferrous sulfate monohydrate 3. CURRENT DATE: April 5, 1999 4. TEST MATERIAL: Moss Control + Lawn Fertilizer, Code #522228; beige/tan and gray granules, with ferrous sulfate monohydrate 24.5% and inert ingredients (fertilizer) 

### 75.5%.

Study/Species/Lab Tax. Core Study #lDate MRID Results Cat. Grade Acute oral toxicity/rat/Product 44770401 LDso > 500 mg/kg (males, III A Safety Labs/6764/JAN-15-1999 females, combined) with no deaths at this dose level, but < 5000 mg/kg (10/10 rats died following dosage at this level) Acute dermal toxicitylratiProduct 44770402 LDso > 2000 mg/kg (males, III A Safety Labs/6765/JAN-15-1999 females, combined) with no mortalities at this dose level Primary eye irritation Irabbit! 44770403 Mildly irritating. Only 3 eyes III A Product Safety Labs/6766! tested. No corneal opacity or JAN-15-1999 iritis observed, but all 3 eyes were positive (score of2 or greater) for conjunctiva! redness, chemosis and discharge at 24 hours, with complete dearing (all scores zero) by day 4. Primary derma! irritation/rabbit! 44770404 Only 3 animals tested. One IV A Product Safety Labs/6767/ animal scored "1" for JAN-15-1999 erythema at 1 hr after patch removal; other 2 animals scored zero. All subsequent (24,48 and 72 hr) scores for erythema were zero. All scores for edema were zero. Core Grade Key: A =Acceptable, S = Supplementary, U = Unacceptable, V = SelfValidated



### 7

## PRIA 2 - 21 Day Content Screen Review Worksheet (EPA/OPP Use Only) 

### 3/23109 21 Day Screen Start Date: 

# :a - 1'3

- 

## a ., Experts In-Processing Signature: {VI 

## F 1If/"fi,N6rgN 

### Date 

# rr -/1-1-0"1 

### Fee Paid: Yes

# Y Division management contacted on issues No Yes Date

_____ _
EPA Reg. Number: 

# 4 - 

# u "J EPA Receipt Date: 

# ??- /3- 

# 07
ItemS for 

### Review Yes 

### No N/A*
1

2



### 3 Application Form (EPA Fonn 8570-1)(link to fonn) signed & 

### complete including package type

Confidential Statement ofFormula all boxes completed, form signed, and )( 

### a) All inerts (link to 

### including fragrances, approved for the proposed uses (see Footnote A) yes no

Certification with Respect to Citation ofData (EPA Form 8570-34) (Link to 

### form) completed and signed (N/A iflOO% repack) Certificate and data matrix consistent
Ifapplicant is relying on data that are compensable, is the offer to pay statement included. (see Footnote B)

there a letter 

### yes

Formulator's Exemption Statement (EPA Form 8570-27) (Link to fann) 

### no

4 completed and signed (N/A 

### ifsource is unregistered or applicant owns the



### Data Matrix (EPA Fonn 8570-35) (Link to fonn) both internal and external copies (PR 98-5) (Link to PR 98-5) completed and signed (N/A if 100% 

# X

5 Selective Method 

### b) Cite-All (Fee category experts use) c) Applicant owns all data (Fee category experts use)


### 5 Copies 

### ofLabel (link to http://www.epa.gov/oppfeadl/labeling/lrm[) 6 (Electronic labels on CD are encouraged and guidance is 

### available)( link to 

# y hUp://www.epa.gov/pesticides/regulatingiregistering/submissions/index.htm#labels



### 1 

# x

### 7 

### Is the data package consistent with PR Notice 86-5 (link to PRN 86-5) 

# X--

Notice ofFiling (link to 8 

### httU:llwww.eI!3.gov/Qesticides/regulatint!/tolerance I!:etitions.htm) included with petitions (link to 

# ;X**http://www.epa.~ov/pesticides/re~ulatinj(/tolerances.htm)** 

### 9 If

### applicable for conventional applications, reduced risk rationale (link to 

# K http://www.epa.gov/opprdOOl/workplanlreducedrisk.html) 

### Required Data (link 

### to httQ://Vt'WW.eQ3.goviQesticides/regulatingLdata reguirements.htm) and/or 

### data waivers. See Footnote C.



### a) List study (or studies) not included with application



### 10

2

### Comments:



## J1/J

## 12 (]) *NI A - Not Applicable

Footnotes A. 

### During the 21 day initial content review, all CSFs will bereviewed to determine whether all inerts listed, including fragrances, are approved for the proposed uses. Ifan unapproved inert is identified, the applicant must either 1) resolve the inert issue by, for example, removing the inert, substituting it with an approved inert, submitting documentation that EPA approved the inert for the proposed pesticidal uses, correcting mistakes on the eSF, etc. or 2) provide the data to support OPP approval ofthe inert or 3) withdraw the application. Removing or substituting an inert ingredient will 

### require a new eSF and may require submission ofdata. All infonnation. forms. data and documentation resolving the inert issue must have been received by the Agency or the application withdrawn within the 21 day period, otherwise, the Agency will reject the application as described below.
To successfully complete this aspect ofthe 21 day initial content screen, applicants are strongly encouraged to verifythat all inert ingredients have been approved for the application's uses even ifa product is 

### currently registered by consulting the inert Web 

### 3i site [link to http://www.epa.gov/opprdOOl/inertsllists.htmIJ and 

### ifthe inert is not 

### approved, to obtain the necessary inert approvalprior to 

### submitting an application to register a pesticide product containing thatinert ingredient. Some inert ingredients are no longer approved for food uses or certain types ofuses. The name and/or CAS number on a CSF 'must match the name and CAS number on this web site. 

### Simple typographical errors 

### in the name or CAS numberhave resulted in processing delays.
Ifan inert is not listed on the inert ingredient web site and the applicant believes that the inert has been approved, the applicant should contact the Inert Ingredient Assessment Branch (IIAB) at inertsbranch@epa.gov and resolve the issue. Copies ofthe correspondence with lIAB resolving the issue should accompany the application. All new inerts except PIP inerts are reviewed by lIAB. The HAB should also be contacted for any questions on what supporting data needs to be submitted for and the Agency's inert review process. Questions on PIP inerts should be directed to the Chiefof Microbial Pesticides Branch [Link to http://www.epa.gov/oppbppdllbiopesticides/contacts bppd.htm 

## J.
When a brand, trade, or proprietary name ofan inert ingredient is listed on a 

## esp, additional infonnation such as an alternate name ofthe inert, CAS number or other infonnation [link to http://www.epa.gov/opprdOOllinerts/tips.pdf]must also be included to enable the Agency to detennine ifit has been approved. Each component ofan inert mixture (including a fragrance) must be identified. 

### In some cases, the supplier ofthe mixture or fragrance may need to provide this infonnation to the Agency. Prior to the Agency's receipt ofan application, applicants must arrange with a proprietary mixture or fragrance supplier to provide the component infonnation to the Agency or promptly upon EPA's request. Ifthe inert ingredients in a proprietary blend (including fragrances) cannot or are not identified or provided within the 21-day content review period, the Agencywill reject the application. During the 21 day content review, applicants should submit infonnation to the individual identified by the Agency when the applicant is infonned ofan unapproved inert. 

### Unapproved Inerts Identified on CSFs
All applications except conventional new products and PIPs Once an unapproved inert is identified on a CSP, the Agency will contact the applicant with the following options:
L Correct the application by, for instance, correcting the inert's identity or CAS number, providing documentation that the inert has been approved, or removing the unapproved inert from the CSF orreplacing it with one that is approved for the application's uses; or 2. Submit the infonnation and dataneeded for the Agency to approve the unapproved inert. Ifthis option is selected and implemented, the Agency may request an extension in the PRIA decision review timeframe to accommodate the inert review/approval process;
4\ 

### 3. Withdraw the application (the Agency retains 25% ofthe full fee for the fee category estimated); or Ifnone ofthese options is selected and implemented bythe applicant within the 21 day content review period, the Agency will reject the application and retain 25% ofthe full fee ofthe category identified. Conventional New Product Applications When the Registration Division identifies an unapproved inert on a CSF with an application for a new product that the applicant has not identified as requiring an inert approval (R311, R312 orR313), it will contact the applicant with the following·options: 1. Correct the application by, for instance, correcting the inert's identity or CAS number, providing documentation that the inert has been approved, or removing the unapproved inert from the CSF or replacing it with one that is approved for the application's uses; or 2. Submit the information and data needed for the Agency to approve the unapproved inert, including any required petition to establish or amend a tolerance or exemption from a tolerance. (This option may change the PRIA category for the application, which could require a longer decision review time and a larger fee. Ifadditional fees are due, they must be received by the Agencywithin the 21 day content review period.) 3. Withdraw the application (the Agencyretains 25% ofthe full fee for the fee category estimated); or

Ifnone ofthe above options is selected and implemented during the 21**~day** 

### content-review period, the Agency will reject the application and retain 25% of the appropriate fee for the new product-inert approval category. PIP Applications When the Biopesticide and Pollution Prevention Division identifies an unapproved inert on a PIP CSF and a request to approve the inert does not accompanythe application, it will contact the applicant with the following options: 1. Correct the application by, for instance, correcting the spelling or name ofthe inert to that in 40 CFR 174, orproviding documentation that the inert has been approved; or 2. Submit the information and data needed for the Agency to approve the unapproved inert. Ifan inert ingredient tolerance exemption petition is required, the petition must be received bythe Agency and the B903 fee paid within the 21 dayperiod. Ifthis option is selected and implemented, the Agency will discuss harmonizing the timeframe for both actions. 

### 53. Withdraw the application (the Agencyretains 25% ofthe full fee for the fee category estimated); or Ifnone ofthe above options is selected and implemented during the 21 day contentreview period, the Agency will reject the application and retain 25% of the fee.

B. A policy on documentation ofoffers to pay is still being developed, however, for a me-too or fast track (similar/identical) new product, R300 or A530, an application without the necessary authorizations ofoffers to pay will be placed into either R301 or A531. The Agencyrecommends that authorizations ofoffers to paybe submitted with other PRIA applications to avoid delays in the Agency's decision.
C. Biopesticide applicants are advised to contact the Agency and discuss study waivers prior to submitting their applicationto theAgency. Documentation ofsuch discussions should be submitted with the study waiver.

6UNI. t:D STATES ENVIRONMENTAL PROTEC11.;N AGENCY WASHINGTON, D.C. 20460



### August 14,2009

OPP Decision Number: D-418493 EPA File Symbol or Registration Number: 4-UIN Product Name: BONIDE MMAX LAWN GRANULES EPA Receipt Date: 13-Aug-2009 EPA CompanyNumber: 4 OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES



### CompanyName: BONIDE PRODUCTS, INC.EPA File Symbol or Registration Number:
Matt Vickers REGISTRATIONS BYDESIGN INC. BONIDE PRODUCTS, INC. PO Box 1019 SALEM, VA 24153-3805

SUBJECT: Receipt ofApplication and 50% Small Business Waiver Request
Dear Registrant:
The Office ofPesticide Programs has received your application, 50% small business waiver request, and cerification ofpayment. Ifyou submitted data with this application, the results ofthe**PRN~86~5** 

### screen will be communicated separately. During the administrative screen, the Office ofPesticide Programs has determined that this Action is subject to a Pesticide Registration Service Fee as defined 

### in the Pesticide Registration Improvement Act. The Action has been identified as Action Code: R301
NEW PRODUCT;IDENTICAL OR SUBSTANTIALLY SIMILAR IN COMPOSITION AND USE TO A REGISTERED PRODUCT;REGISTERED SOURCE OF ACTIVE INGREDIENT;SELECTIVE DATA CITATION ONLY FOR DATA ON PRODUCT CHEMISTRY! ACUTE TOXICITY! PUBLIC HEALTH PEST EFFICACY, WHERE APPLICANT DOES NOT OWN ALL REQUIRED DATA NOR HAS AUTHORIZATION LETTER FROM DATA OWNER; The fee associated with this action is 

### $ 819. Payment 

### in the amount of$ 2,289 has been received. A refund 

### in the amount of$ 1,470 will be issued.

### Your request for waiver has been forwarded for review. You will be notified in vvriting when a detennination is made regarding your request. Ifyour waiver request is approved, the decision review time period will start on the date ofapproval. Ifyour waiver request is denied, you will receive an invoice for the outstanding balance.
Ifyou have any questions, please contact the Pesticide Registration Service Fee Ombudsman at (703) 305-6249. Sincerely,**~**

# 9Jlt~iilProc~~ ynn9'tDgy & 

### Resources Management Division

# IFee for Servicel**~** 

# {855762;-

,------

I 

### This package includes the following

@ 

# New Registration
oAmendment for Division



# I**~** 

# Studies?**~** 

# Fee Waiver? 

# : v Risk Mgr. 

# []TI i D 

# vol pay % 

# Reduction: Receipt No. 

# s-I 855762 

# i=====: EPA File Symbol/Reg. No.

:=1 

# ===4=-=U=IN==: Pin-Punch Date: 1 

# 8/13/2009 

# L______________________________

__ __ n This item is NOT subject to FFS action.**~** 

# A-ctroITCodB: 

# II Parent/Child Decisions: 

# i I Requ

. [



# , [I 

# i Gr dO) 

# ,I I Amount Due: 

# $ 

# /49 3£ :::::

# J [**Y/N>1~' ),~** **@/n/~** 

# . }!. 

## Inert Cleared for Intended Use I'i: 

## Uncleared Inert In 

## Product Reviewer:

# ~ Date: 

# Sfr1

Remarks:



# ..... /k?;h/-**~ct1't4 C-f;/~~ YO~~~arl~**  -"\

# ~ cJ;rk

# tf!tt**~Acr ~**  -

# FEE 

# FOR SERVICEBONIDE PRODUCTS, INC. 6301 SUTLIFF RD. ORISKANY, NY 13424 

### \

***Two Thousand Two Hundred Eighty-Nine & No/100 US**do~lars**
DATE 08/12/09 PAY**~6~~** U.S. EPA OF 

## 78131**7813~**

AMOUNT

$2,289.00:

VOID AFTER 90 OAYS

# ~~R~~**·**
BONIOE PRODUCTS, INC. 6301 SUTLIFF RD. ORISKANY, NY 13424 Vendor No: USEPA / Name: U.S. EPA Invoice**08~209** Ref Inv Date 08/12/09 

# h:=EjJCI(QN

# L1~c:- Inv Amt 2289.00 Discount 0.00 Adj Amt 0.00 

## 78131 78131 Amt Paid

2289.00



## YESTre<OG'

# t;;a,'S(l\.ilr[~,0 l>47C11 

## :S(/J,(Oq ']3Gl\lrtt

# H/v{fI'" L4wrJ tR.MJelleO;, 

# t /
MPUcA=0

(Acct: 10109-002) Check Date 08/12/09

MldCustom**Tota~**

" , !J , 

# . J' , " 

### " , , , " 

# .
• " 

### , , " 

### ,
, 

# . , ,> >,

, , , >

### • 2289.00Print Form 

# .... ". Off ,.".,.. ".,.,. , 

# ..""

.... No. 2070-0000 United Stat •• 

### .leglst,ation OPP Id.ntifier Number 

# oEPA 

# -- Environmental Protection Agency 

## f- Amendment Wahlngton, DC 20460 

### Other Application for Pesticide· Section I 1. CompanyJPrDduct Number 2. EPA Product tMnager 3. Propond CI.Hiflcation**~** 

## UJIv' Joanne I. Miller 

# 0 NOM 

# o R...tricted 4. C:re'"J{prodl,lct INam.1 PM.

Bani e Max lawn Granules 23 S. Namt and Addr

... of APflUc.nt (Include ZIP CQdaJ 6. Expedited Review. In accordance with FIFRA Section 3/el/31

Banicle Products, Inc. /bllil. 

### mv product is similar or identical in composition and labeling 6301 SutliffRoad to, 538-223, 802-543, 8660·178, 9240-8 Oriskany, NY 13424 II EPA Reg. No. 

# D Ch.ckHthi6 is. new.ddrU3 Product Name 

### Section

- II 

# 0 Amendment· Explain billow. 

# 0 Final printed 11IbeI, in I'O.pon

.. to Agancy lano, dated 

# 0 RalJUbmi-.ion In rolpon" to Agency ,.ttor dated 

# El "Me Too" Application. 

# 0 Notlflcation· Explain b.low. 

# 0 Oth..-

- Explain tHllow. Explanation: u•• tdditional p.g"5) II nee... ary. (For .octlon I .00 S.ctlon 0.1 Substantially similar in formulation, toxicitycharacteristics, and application rates to other granular moss control herbicides labeled for residential use: EPA Reg. Nos. 538-223, 802-543,8660-178, 9240-8.


### Section • III 1. M.ttrit! Thit ProductWIllis. P.ck.ged In: Child-R.sitt.nt Peck.gin; Unit Packaging Wtt.r Solublo P.ck.g1ng 2. Typ. 01 Container

# ~l'". .:.:.;,;. V ••

# ~ y"

# §~'. X No 

## X No No X Plutic Glo

.. • Certifit:.tiDn must If -V

..- No. per II-V.s" No. p.r P.p.,. Unit P.ck.ging wgl. contein.r P.ck.go wgt contllinot Othor (Specifyl lHI $ubmlttfHI I 3. loc.tion of N.t Contont. Inl.rrna60n 4. Sizols) R.tall Contain.r 5. location of label Oir.ctiont 

# I8J Lab. 

# o Container 20lb bag

### ~on""" On lebeUng aooomp.nying product 6. MIInner in Whioh label i. Affiud to Product 

# F== Uthograph 

## U Oth.r Pep.r**~Utd** St.1'ICi iId

### Section· IV 1. Cont.ct Point IComplttt ittl1l$ diuctly b.!ow for idMtmc.tion of/ndiv/dUfl! to b. conrl'cttd, Hntct$.PI'Y, to proc
..thi$**tppli~tion.J** N_ Titl. T.lephon. No. (Includ. Are. Cod.1 Molly Hickman Consultant to Registrant 971-219-8084 Certif"lCation 6. Otto Applic.tion I c.rtify thllt the ttatement. I hav'm.d. on thi. lorm .nd .u attachm.nts thereto aro truo, ..::cur.te.nd compl.te. RltCeived Iecknowledge that.nyknowingly flll.o or misl.ading .t.tem.nt may b. puni.habtt by fine or impri.OlV'!'lont or (Stamped' both under applieabl' ."". 2. Slgnatur0'1. 

# j/(A 3. TrtI. V.P. Operations 

### " , " 

# .. , , 

### , , , 

### " , 

### ,**4.T~Neme** 5.D.te 

### , 

# · , 

# · MattVickers 8/4/2009 "'''' 

### , ,**,,~,}.** 

### , , 

# ·

• EPA Form 8570-1 IR.v. 8-$41 Pr.VlOU. aditiont til. obsolete. , ,1.IIt-w "Appllc

....t Copy

" >, " ,J


### , , 

### , ,

## Donide 

# Products, Inc.

August 12, 2009

Document Processing Desk (REGFEE) U.S. Environmental Protection Agency 6301 Sutliff Road oriskany, NY 13424 Telephone: 315-736-8231 ext 243 Fax: 315_736_7582 Email: mattv@bonide.com



### FedEx:868516232767

Office of Pesticide Programs/RegistrationDiv. (7505P) Room S-4400 One Potomac Yard (South Bldg.) 2777 S. Crystal Drive Arlington, VA 22202-4501 RE: R310 "Me-Too" Application to Register EPA Reg. No.**4-~** 

### Bonide MMax Lawn Granules Please accept and process this application for registration of a me-too end-use pesticide product containing ferrous**su~ate** 

### monohydrate as the active ingredient. The following documents are submitted in support ofthis application for registration: 1) Copy offee payment with smarr business waiver documentation 2) Application For Registration Form 8570-1 3) Basic and Alternate Confidential Statements of Formula, Form 8570-4 (2 copies each) 4) MSDSs and/ortechnical data sheets forferrous sulfate monohydrate 5) Certification with Respect to Citation of Data, Form 8570-34 6) Data Matrix, Form 8570-35, with attachments 7) Product Chemistry Series 830 Data (3 copies) with Transmittal Document 8) Proposed labeling (5 copies) 

### Should you have any questions about this application, or need addRional information, please do not hesitate to contact me or our authorized agent for this application, Molly Hickman at 971-219-8084, or email.molly.hickman@comcast.net



### EnclosuresTRANSMITTAL DOCUMENT

SUBMITTOR: BONIDE PRODUCTS, INC. 6301 SutliffRoad Oriskany, NY 13424

REGULATORY ACTION IN SUPPORT OF WHICH THIS PACKAGE IS SUBMITTED: Application for Me-Too Registration dated 8/4/2009 Bonide MMax lawn Granules, EPA Reg. No.4-XXX

TRANSMITTAL DATE: 8/4/2009

LIST OF SUBMITTED STUDIES: Subpart 0 - Product Chemistry Series 830

COMPANY OFFICIAL:

# ~ Signed: tU.u

. :s::: Matt Vickers,

.**~** atrons 315-736-7S82

# ,OMBI '''"

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 1200 Pennsylvania Avenue, N.W. WASHINGTON, D.C. 20460 Paperwork Reduction Act Notice: The public reporting burden forlhis collection ofinfonnation is estimated 10 aver.tge , ' _' ,. ) , ; , and 0.25 hours perresponse for reregistration and special review activities, including time for reoding the instructions and completing the necessa.;:"**f;~~:- -~**  

## , , COl1lllll:nts regarding burden estimate OTany other aspect ofthis collection ofinfonnation, inchlling suggestions for reducing the burden to: Director, Collection StralegiesDivision (2822T), U.s. Environmental Protection Agency, 1200 PennsylvaniaAvenue, NW", Wa::hington, DC 20460. C'.c ,r.1t.,serd1he completed form to this IIddress. : J, 1 1 > Certification with Respectto Citation ofData Name, Address, and Telephone Number 

## : '" , EPA Registration 

### , 

### , , ,

Active InQredientrs) and/or reofesenlaUve test comoound(s) I**D,~** 81412009 General Use Pattem($) (list an those claimed for this product using 40 CFR Pari t58) ; Pmduct Name 

## I Boo;'. I NOTE: Ifyour product is a 100% repClckaging ofanother pW'Chased EPA-registered product labeled forall the same uses on yourmbel, you do not need to submit this fonn. You must submit the Fonnulato(s Exemption Statement (EPA Fonn 8570-27). 

# o
o I am respondino to a**Data.call~n** Notice, aoo have included w'rth this fonn a list ofcompanies sent offers ofcompensation (the Data Matrix fonn Should be used forthis purpose).

SECTION I: METHOD OF DATA SUPPORT (Check. I am using the cite-all method ofsupport, and have included with this fonn a list ofcompanies sent offers ofcompensation (the Data Matrix fonn should be used forthis purpose). I am using the selective method ofsupport (or cite-an option under the selective method), and have included with this fonn a completed list ofdata requirements (the Data Matrix fonn must be used). SECTION 11: GENERAL OFFER TO PAY IRequired if using the cite-aU method orwhen using the Clle-all option under the selective method to satisfy one or more data requirements) 

# o I hereby offer and agree to pay compensation, to other persons, with regard to the approval ofthis application, to the extent required by FIFAA

; Ii Ii ; ',.fu,!" fu" 

## , ; 

# '"" I I,**o~o"'?"** in effect on the date 

## "'"

, ; 

# ;b;.,,

, ; SECTION 111: CERTIFICATION

Ii ,orthis Data-Call

..ln response is supported by all data submitted ordted in the**~'~~t(~f:50n,** i(the cite-an option or cile-all opUon under the selective method Is I concem the properties oreffecls of this product or an idenUcal or**~ and~<:,~!~**  .a
..type ofdata thatwollid be required to be submitted underthe data I sought the initial registration 01 a product of identical or simUarcomposition and

I certify that foreach exclllsive use study cited in SllPPort of this registration or reregistration, that I am the original data submitteror that I have obtained the wmten pennission 01 the orig'lnal data submitterto cUe that study. I**~,~fy** that for each study cijed in support of this registration or reregistration that is not an exclusive use study, either. (a) I am the original data 

# I**~§~; f~:~'~** **"1~~~~~]~~P~·~~ff;"2;:O~"}O~f::.~'~O~";,;g~I"'i'~',~"~.~'~"r:bm~i'ltre!~"rtoi**use the study in support of thiS application; (c) all periodsof eHgibility for ,; (d) the**~UdX-iS** in the public literature; or(e) I have notified in writing the company that submitted the study and have

. i and/or 3{c)(2)(B) ofFIFRA; and 01) to commence negotiations to determine the ,ifany,to the**~5tudy.** 

# I**:~:~~:~:~~:~~:::~~:~:~~:~;~~~~~~~:~i::1~** is required, copies ofall offers to paY compensation and evidence oftheirdelivery in h.5ections**:~\~.** are available and will be submitted to 1he Agency upon request. Should I fail to produce such**FI~RA.** to the Agency upon request, I the Agency may initiate action to deny, cancel or suspend the regisbation ofmy product in confonnity with

I certify that the statements I have made on this fonn and all attachments to it are true, accurate, and complete. I acknoWledge that any knowingly false or misleading be punishable by fine or Imprisonment or both under appllcable law. 

## I 

## 0,,. Typed Of Printed Name and ntla 8/4/2009 Mati Vickers, V.P. OperationS il I....FormApprovedOMBNo.2070-0060.-l-UNITEDSTATESENVIRONMENTALPROTECTIONAGENCY401MStreet,S.W.... . . ..WASHINGTON,D.C.20460.Paperv:<:rkThepubticreportingburdenforthiscoUecfionofinformationisestimatedtoaverage0.25hoursperresponseforreglslratlonactivitiesand0.25hoursperrespon5eforrereglsl1'8tklnari{!speclalnrvtevtactMlies,includingfuleforreadingtheinstructionsandcompletingthenecessaryforms.SendcommentsregardingtheburdenestimateoranyotheraspectofthiscoMection01information,ili'cludlng5l!g'gesJionsforreducingtheburdento:Director,OPPEIntormaUonManagementDivision(2137),U.S.Erw!ronmentalProtectionAgency,401MStreet,S.W.,Washington,DC20460.Donotsendtl:ltf('r,lJt1thisaddress,<. <..·DATAMATRIX·.·iPage1:lf1Date-"-"" "EPARegNo.lFileSymbol4-XXX(appsubmitted8/4{2009)c • cAop!lcant'slReaistranl'sName&AddressProductBonldeProducts,Inc.,6301SutliffRoad,Oriskany,NY13424BonideMMaxLawnGranulesIngredienlFerrousSulfateMonohydrateGuklellneReferenceNumberGuidelineStudYNameMRIDNumberSubmitterStatusNoreSeries830ProductChemistry-EPnotassignedBonldeProducts,Inc.OWNapp81412009870.1100AcuteOralToxicity-Rat-EP43313903ScoltsCoOLD870.1100AcuteOrelToxicity-Rat-TGAIWaivedIronSaltsREDPLattached870.1200AculeDermalToxicily-EP43313907ScoUsCoOLD870.1200AcuteDermalToxicity-TGAIWaivedIronSeltsREDPLattached870.1300AcuteInhalationToxicity-Ra1-EP43313905ScottsCoOLD870.1300AcuteInhalationToxocity-TGAIWaivedIronSallsREDPLattaChed870.2400PrimaryEyetrritation-Rabbit44770403UnitedIndustriesPAY870.2400PrimaryEyeIrr!laHon·Rabbit43313904ScottsCoOLD8702500PrimaryDermalIrrttallon43313906ScottsCoOLD870.2500PrimaryDermalIrritationWaivedIronSaUsREDPLattached870.2600DarmalSensitization43313908ScotlsCoOLD870.2600DermalSensitization41763701IronSaltsTaskForceOLDIISignatureNameandTItleD,IeMallVickers,V.P.Operations08104/2009':::CA,,_EleclTonic...,,"........."..!....

# •

.. . . ''- Unifod Statos Environmontal Protedion Ag."")' OfflCO of Pr8Vontion. Pesticides and Toxic Substances (H-750SW) 

# &EPA 

# ReregistraUor;. .••.. EPA**73B-~** Fobruary-' 

# Eligibility Do.cu."ent (RED)

............

Iron SaltsIRONIISULFATEMONOHYDRATEGUIDELINEGUIDELINENAME"§iS8:I::;OEnvironmentalFateAJIfatedatarequirementshavebeenwaived.§158.135Toxicology81-1Acuteoraltox.rat81-2Acutedenna!tox.rabbit81-3Acuteinhal.toxrat81-4Primaryeyeirrnti6n-rabbit81-5Primarydenna!irritation8HDermalsensitization/Guineapigs§l58.145EcologlCJlImeets71-l(a)AcuteAvianOralToxicity-Quail/Duck71-2(a)AvianDietaryToxicity-Quail/Duck71-2(b)Acuteaviandiet.duck72-1(.)Freshw.terFishToxicity-Bluegill72-1(c)Fishtoxicityrainbowtrout72-2(.)FreshwaterlnvertdJraleToxicityUSEBIBLIOGRAPHICSITESCITATIONAllAllAUAllAllAllAllAllAllAUAllAllWAIVEDWAIVEDWAIVEDWAIVEDWAIVED41763701400919024009190340091904400919054009190640091907111

# I

B. !
HUman Health Assessment



### , , , 

### , 

### , , 

### , 

### , L ToxlcoJogy Assesstnent 

### " 

### , , , 

### " The toxicoJogica1 data base on iron (ID)**suJfa~1'** i,ro,-, (II)**~l\lfate** 

### monohydrate, and iron (II) 

### sulfate heptahydrate is**ad~.JatO** 

### anti wm 

### support reregistration eligibility. : ) ,) ,") :' , ,**~**


### a. Acute and Subchronic Toxicity

ACUTE TOXICITY VAWES


### TEST RESULT TOXICITY Iron III Sulfate CATEGORY Oral LO,,--rat 1487

- 2102 mg/kg 

# m Inhalation LCSOM-rat > 1,10 mgiL 

# m Dermal**LD50~-rabbit** >2000 mg/kg 

### III Eye Irritation 

### corrosive I Dennal Irritation corrosive N Dennal Sensitization 

### negative 

## - Iron (111) sulfate, in an acute oral study in rats. had an LDso of 1487 mg/kg in females and 2102 mg/kg in males. An acute dermal 

### toxicity test in rabbits with Iron (In) 

### sulfate found an LD50 greater 

### than 2000 mg/kg. An acute inhalation toxicity study in rats using iron (III) sulfate determined the LCso to be greater than 

### J. 

### JO rngfL.
Iron (II) sulfate heptahydrate, in an acute 

### oraJ study 

### in rats, showed an LO. of 1389 mg/kg and an acute oral study 

### in rabbits showed an LD", 

### of 2778 mg/kg(4). The LO

.. determined for this compound in mice was 1520 mg/kg(4). A sensitization study using guinea pigs with iron (II) sulfate monohydrate and iron (III) sulfate found no indication of contact sensitization by this compound.



### 7



### )

### 2. )


### b. Mutagenicity

\ -, , 1 , 

### A mutation 

### study in 

## lik!lli reported pp3(tive 

### nsult'5 'af,3,}**~** ; ; 

### umoIlL(4). With due regard for the**continuing'p';xPOs11'\~** 

### LicP' huciti**~:;** beings have had to the iron and sulfate components of these chemlcals 

### over many generations, it 

### is considered unlikely**-~~** 

### t1As,**~~** 

### result in microorganisms has any bearing on probable**iffect~** in;In,m¥s or other mammals at the levels expected from use 

# oftheie' CoMpo»nds as 

### pestiCides. ' - '" -, "



### c. Metabolism
Iron sulfates are normal constituents of the diet and are 

### metabolized and utilized by the body. 

### d. Other TO"licological 

### Consideration The toxicological data on iron sulfates within the A d in the literature are adequate for assessin risk to humans. Not all 

### of the toxiCity data usually requtred for pesticide registration or reregistration are necessary for the present uses of iron sulfates. There are some 

### unusual factors in this case which indicate that specific studies 

### to fulfill the usual data requirements are not necessary to 

### regulate these substances as pesticides. Iron sulfates are normally present in the environment. They may be present in foods naturally and as added ingredients. There is no reason to 

### expect that pesticide usage in 

### accordance with the product label or labeling accompanying the product 

### will constitute any hazard beyond that from ordinary exposure. Exposure Assessment

3. 

### Dietary Dietary exposure to iron (HI) sulfate, iron (II) 

### sulfate heptahydrate, and iron (II) sulfate monohydrate is not expected to occur from pesticidal use. There are no active products involving pesticidal uses on food or animal feed. Therefore, there are no tolerances or exemptions from the requirements of tolerances established for iron salts. Since there are !to toxicological endpoints of concern and no food useS, no risk assessment was 

### performed for dietary exposure. Iron (11) sulfate is generally recognized as safe as noted in 

### 40 CPR 180.2(a). The Food and Drug Administration has 

### affirmed that iron (lll) sulfate and iron (11) sulfate (hepta and monohydrate) are generally recognized as safe (GRAS) for use in food as flavoring agents and nutrient supplements, respectively, 

### with no limitations other than


### 8

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### )